UNITED STATES DISTRICT COURT
for the
District of Connecticut
Dr. Ernest C. Garlington Case No. ____________________
(Plaintiff)
V. Jury Trial: X YES ____ NO
Susan Clifford
78 Acorn Rd.
Madison, CT 06443
Coldwell Banker Real Estate Agency
752 Boston Post Rd
Madison, CT 06443
(Defendants)
Date: May 2, 2017
VERIFIED COMPLAINT FOR
DAMAGES AND DECLARATORY RELIEF
I. The Parties to this Complaint
A. The Plaintiff.
Name: Dr. Ernest C. Garlington
Address: MacDougall Walker Correctional Institution
1153 East Street South
Suffield, CT 06080
B. The Defendants.
Name: Susan G. Clifford (a.k.a. Susan Clifford, S Clifford, Susan Gallagher, Susan G McManus)
Address: 78 Acorn Road
Madison, CT 06443
Telephone: 203-215-7265
E-Mail: susan.clifford@gmail.com
Name: Coldwell Banker Real Estate Agency
Address: 752 Boston Post Road
Madison, CT 06443
Telephone: 203-245-4700
II. Basis for Jurisdiction.
1. This is a civil action filed by the plaintiff, Dr. Ernest Garlington, a state prisoner, pursuant to United States Code Sections 42 USC 1983 and 1985 (2) and (3), alleging conspiracy to obstruct the due course of justice with the intent to deprive the plaintiff of equal protection of the law, privileges, communities, liberty and pursuit of happiness, for which the plaintiff seeks damages and declaratory relief.
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2. Jurisdiction of this Court is invoked pursuant to 28 USC 1331 in that this is a civil action arising under the Constitution of the United States.
3. Jurisdiction of this court is invoked pursuant to 25 USC 1343, in that this is a civil action seeking to redress the deprivation under color of state laws, of rights secured by Acts of Congress providing for equal rights of persons within the jurisdiction of the United States.
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4. Jurisdiction of this Court is invoked pursuant to 28 USC 1367, which provides for supplemental jurisdiction.
III. Parties
1. The plaintiff, Dr. Ernest Garlington, at all times relevant to this complaint was residing in Marion Southington, CT and was subsequently committed to the custody of the Commissioner of Connecticut’s Department of Correction (CDC) located in McDougall Walker Correctional Institution (MWCI), 1153 East South Street, Suffield, CT 06080.
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2. Defendant Susan Clifford at all times relevant to this complaint resides in Madison, CT and was employed by Coldwell Banker Real Estate Agency located in Madison, CT 06443. Mrs. Clifford is being sued in her individual capacity.
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3. Defendant Coldwell Banker Real Estate Agency, at all times relevant to this claim was located at 752 Boston Post Road, Madison, CT 06443. This defendant is being sued in its individual and official capacity.
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IV. Background
To understand the historical facts of this complaint it is necessary to explain in detail the relationships of the parties involved. See Exhibit A – Press Release 1, 2 and 3.
V. Plaintiffs Lawsuit Statement: Defendant Criminal Actions and Motive.
1 The Plaintiff, Dr. Ernest Garlington, is suing the defendant, Susan Clifford, for committing criminal acts against Dr. Garlington that have kept him in prison for a wrongful conviction in which he is serving a 33- year sentence. These criminal actions have effectively revoked Dr. Garlington’s Constitutional Rights to a fair and impartial (habeas) trial.
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2. Criminal Actions: Susan Clifford made secret phone calls to Dr. Garlington’s attorney, Theodore Koch (Public Defender), to coerce him to withdraw from the Garlington habeas case. On November 13, 2015 at a habeas court hearing, (Connecticut Superior Court Case Docket: 124004333-S), Dr. Garlington’s third public defense attorney, Attorney David DeRosa, described how he was informed about Susan Clifford’s secret calls to Attorney Koch after the Public Defender’s Services transferred the case to him from Attorney Koch. As per court instruction, Attorney DeRosa met with Attorney Koch to provide background on the habeas case. Attorney DeRosa stated, “Mr. Koch said the case just got crazy. People calling me and everything else and I just had to withdraw.” Attorney DeRosa additionally stated in court that “Susan Clifford [Judge Clifford’s wife] contacted Attorney Koch regarding Dr. Garlington’s case.” The presiding judge (William H. Bright, Jr.) responded, “I can understand why Mr. Garlington would conclude that the only reason that Judge Clifford’s wife would be calling Attorney Koch would be to pressure him about the case. That’s a reasonable inference for him to draw.” Dr. Garlington explained to Judge Bright that “Susan Clifford knows that her falsified signature is going to become a part of this habeas.” At which time, the Judge asked Attorney DeRosa, “Are you prepared to, if you need to, put Judge Clifford’s wife on the stand and question her about this alleged fraud and the conversation with Attorney Koch?” To which Attorney DeRosa responded, “Sure, Your Honor.” The defendant also blackmailed Koch by employing her husband, Judge Clifford, to threaten to ruin his career by making Attorney Koch’s “clients suffer” if he did not withdraw from the plaintiff’s case (see 22, 23, 24).
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3. Motive: Susan Clifford’s motive is understandably the fear of being locked up in a federal women’s prison for up to 20 years for FRAUD. Susan Clifford made calls to Public Defender Theodore Koch coercing him to withdraw from the case to avoid being arrested by the FBI for fraudulently forging the signatures of the Dolan’s on an $8.7M Coldwell Banker Real Estate document with the intent to deceive the Superior Court. As Dr. Garlington’s criminal trial’s presiding judge’s wife, there was a definite conflict of interest with a possible $240,000+ commission on the sale of the Dolan’s beachfront home to NBA star Ray Allen, the alleged victim’s stepson.
VI. Facts: Case History
4. In August of 2005, the Defendant, Mrs. Susan Clifford’ close friends of thirty years, the Dolans met with Ray Allen (the stepson of Dr. Hopson, the alleged victim in the plaintiff’s criminal trial) at their $8.7 million mansion in Madison, CT to consider buying their home. The Allen family loved the home, but could not agree on a price.
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5. In October 2006, the Defendant, Mrs. Susan Clifford, a realty agent for Coldwell Banker Real Estate Agency, is hired by her friends, the Dolans, to sell their waterfront mansion for $8.7 million dollars. Mrs. Clifford’s commission would be over $240,000, and the Dolans profit from the sale would be between two and three million dollars. However, the defendant was also under pressure to sell the home because the Dolan’s could not afford to pay the exorbitant annual $30K to $40K tax bill. Judge Clifford said, “it’s sad” (jury selection transcript) they could lose their home. The Allen family remained interested in the home when the defendant became the Coldwell Banker listing agent.
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6. In July 2007, the Defendant’s husband, Judge Patrick Clifford, was assigned the plaintiff’s highly publicized criminal case. He has been described by friends as a competitive basketball fanatic who is also friends /acquainted with Ray Allen and has had a close friendship with the Dolans for more than thirty years.
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7. At this point, the Defendant, Susan Clifford, and her husband should have agreed that either he recuse himself from the highly-publicized Garlington case, or she remove herself as the realty agent for a home sale involving the alleged victim’s stepson. This would have avoided the overwhelming “Conflict of Interest” and “Lack of Appearance of Impartiality” as provided by Connecticut’s General Statutes 51-39, 51-39 and Connecticut’s Practice Book Case of Judicial Conduct, Rule 21.
8. In August 2007, prior to the plaintiff, Dr. Garlington’s trial, the Allen’s contacted Susan Clifford’s friends, the Dolans to express that they were still very much interested in their home and wanted to negotiate a selling price in which the Defendant, Mrs. Clifford would receive over $240,000.00 in commission.
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9. In October 2007, the Defendant, Susan Clifford, was the subject of a secret discussion caught on tape during the jury selection of the criminal trial of plaintiff, Dr. Garlington. Susan Clifford’s husband, Judge Patrick Clifford, States Attorney Prosecutor Russell Zentner and Defense Attorney Willie Dow were unaware that they were being recorded. Judge Clifford said that “she (Susan) better start shaking the money tree” because “they needed money to pay for their daughter’s upcoming wedding”. Attorney Dow encouraged the judge remarking that by selling the house to Ray Allen after the trial, he and his wife could collect the $240,000+ in commission for their retirement.
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10. It is reasonable to believe that the defendant, Mrs. Clifford and her husband had discussions with their close friends the Dolans regarding the Ray Allen/Dr. Garlington case, considering that Judge Clifford was comfortable talking about Susan selling the $8.7 M home to Ray Allen, the stepson of the alleged victim in the case over which he was currently presiding.
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11. In November 2007, the plaintiff, Dr. Garlington, was wrongfully convicted. Following the trial, but before his sentencing, he hired the law firm of Denner and Pellegrino, located in Boston, MA.
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12. In January of 2008, Dr. Garlington informed Attorney Denner that during jury selection he overheard a court officer say that the defendant, Susan Clifford, a Coldwell Banker real estate agent, was going to sell the Boston Celtics NBA basketball star, Ray Allen an $8M mansion.
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13. On March 14, 2008 Attorney Denner exposed the defendant, Susan Clifford, and the conflict of interest by filing motions to disqualify her husband, Judge Patrick Clifford and requesting a new trial for the “lack of an appearance of impartiality” and the impropriety of the court.
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14. Forgery/Fraud – States Attorney Prosecutor Zentner filed a motion with an attached memorandum of law in opposition to Attorney Denner’s motion to expose Susan Clifford and the conflict of interest and disqualify Judge Clifford. Zentner submitted (fraudulently) documentary evidence purportedly signed by the Dolans (forged by the defendant, Susan Clifford) stating that Mrs. Clifford, the Coldwell Banker real estate agent, would not receive a commission if she sold the $8.7M beachfront mansion to Ray Allen. The Dolans, having been friends with the Cliffords for decades, colluded with the defendant and should have known that the documents submitted as evidence were forged with the intent to deceive the Superior Court and obstruct the due course of justice, i.e., denying Dr. Garlington from vacating his wrongful conviction due to the conflict of interest between the Dolans and the defendant.
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15. Attorney Denner’s motion to expose Susan Clifford’s conflict of interest and disqualify her husband, Judge Clifford, was assigned to Judge Holtzberg who should have recused himself due to a blatantly biased disposition. He was the presiding judge in the criminal trial of Robert Santos. Santos was the individual alleged to have been hired by the plaintiff, Dr. Garlington, to murder Derek Hopson. In a separate trial five years prior to Dr. Garlington’s trial, Robert Santos chose a nonjury trial and was found guilty by Judge Holtzberg and was sentenced to 18 years in prison. Santos testified that he did not know Dr. Garlington. If he lied and said that Dr. Garlington hired him to kill Derek Hopson, it is believed that Santos would have received less than half of his 18-year sentence because Derek Hopson was neither murdered, nor injured.
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16. The defendant, Susan Clifford, submitted fraudulent documents to the Superior Court as a response to the plaintiff’s motion for conflict of interest disqualification of her husband, Judge Clifford. The request to vacate the conviction of Dr. Garlington was denied by a biased Judge Holtzberg. Judge Clifford was allowed to remain on the plaintiff’s case and prepare for sentencing.
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17. The defendant, Susan Clifford’s husband was enraged that the plaintiff had exposed his wife, Susan, for the conflict of interest in the $8.7 million-dollar real estate scandal. In retaliation, Susan’s husband sentenced Dr. Garlington to 33 years in prison, in a case where the alleged victim was not injured and the plaintiff had never been in trouble with the law.
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18. In June 2010, while going over the documents proffered in the hearing to expose the defendant, Susan Clifford, for conflict of interest and to disqualify her husband, Judge Clifford, the plaintiff discovered discrepancies in the purported signatures of Mrs. Clifford and the Dolans.
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19. In December 2010, the plaintiff received the results from an independent, certified document examiner (CDE), Ms. Eileen Hurley, of 3 Adams Street, Merrimac, MA 01860.
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20. The analysis confirmed to the highest degree of professional certainty that the signatures on the documents submitted to Judge Holzberg by States Attorney Prosecutor Russell Zentner were forged by Mrs. Clifford in an attempt to cover up the fact that she would have received over $240,000 in commission from the sale of the Dolan home to Ray Allen.
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21. If the defendant, Susan Clifford’s forgeries were exposed at the time of the hearing, the wrongful conviction would have been vacated and Dr. Garlington would be a free, innocent man. Sadly, he has spent the last nine years of his life in a maximum-security prison. The last 5 years of the total of 9 years is due to Susan Clifford’s secret telephone conversations involving intimidation, coercion and collusion with Attorney Theodore Koch. These criminal actions violate Connecticut’s penal codes 53a-139, forgery in the second degree on conspiring with others to obstruct the due course of justice with intent to deny the plaintiff equal protection of the law in violation of Untied States codes 42 USC 1983, 1985 (2) and (3) along with the 5th, 6th and 14th amendments to the United States Constitution.
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22. Based on court records, Mrs. Clifford must have coerced Attorney Koch to withdraw from the case between August 15, 2012 and December 5, 2012. Attorney Koch was officially assigned the Garlington case from the Public Defender Services on August 15, 2012 (see exhibit B). Attorney Koch sent Dr. Garlington a letter on December 5, 2012 (Exhibit C) stating that he had to withdraw from the case because he believed Judge Clifford would retaliate against him and his clients.
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23. “Dear Ernie: When I told you I would take your habeas case, I did not know Judge Clifford. Then he was assigned to be the Presiding Judge of New London and I got to know him from that. I knew that you and I have discussed your claims against him and you have somewhat tamped them down on my advice, but I do not want to restrict you from making as powerful an attack against your conviction as you wish to make. There arises a serious conflict of interest when I have cases before Judge Clifford in which I am asking him to be as fair to my client as possible, and on the other hand, I am accusing him of insidious corruption in a habeas. I don’t think he would handle that well and my trial level clients may suffer from it.” (Emphasis added) Finally, “All I can say to that is, what matters are the facts. A good investigation (Emphasis added) goes a long way.” Regards, W. Theodore Koch III
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24. Blackmail – Per this letter, it appears as if the defendant, Mrs. Susan Clifford, employed her husband, Judge Patrick Clifford, to meet with Attorney Koch and blackmail him Ë— either you withdraw from the Garlington case or your “trial level clients may suffer.” Not only did the defendant have her husband blackmail Koch by threatening to make his clients suffer and potentially destroy his career, but also used other coercive tactics.
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25. The Defendant likely had other people call to intimidate and coerce Attorney Koch, the Public Defender. Attorney DeRosa stated that Attorney Koch said there were several people making secret calls to force Koch to withdraw from the case. Mr. Koch said, “The Garlington case just got crazy. People calling me and everything else and I just had to withdraw.” It seems as if defendant, Susan, had many individuals compel Koch to withdraw between August 5, 2012 and December 5, 2012. These criminal acts occurred within the 5 year federal time limits to file a federal civil suit.
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26. On January 10, 2013, at hearing, CT Superior Court Docket –TSR-CV12-4004333-S, Attorney Ted Koch requested to withdraw from representing Dr. Garlington citing concerns about his present and future relationship with Judge Clifford. In court transcripts he is quoted as saying: “I want to say upfront that my reason for withdrawing from (Dr. Garlington’s case) is not personal to Dr. Garlington. We have an amicable relationship. He’s not being unreasonable. Without going into details, Mr. Garlington has some powerful claims against Judge Clifford.” As Attorney Koch stated in the letter he expressed in court, if he brings these insidious claims against Judge Clifford, he’s not sure Judge Clifford would be fair to him or his clients. Therefore, it is essentially a conflict of interest question. Judge Solomon appeared to be disgusted that Attorney Koch was withdrawing from the case because he felt that Judge Clifford had a responsibility to be fair to Attorney Koch. Consequently, he initially denied Attorney Koch’s motion to withdraw. However, the court asked the plaintiff whether he would like to continue with the Public Defender, Attorney Koch, or allow him to withdraw. The Plaintiff allowed Attorney Koch to withdraw from the case based on Attorney Koch’s unwillingness to pursue Susan Clifford’s fraud (See Court Hearing Transcript.)
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27. NOTE: Chief Justice Patrick Clifford has immunity, therefore, he is not a defendant in this lawsuit. However, if at any point the Plaintiff can substantially prove that Judge Clifford’s blackmail and other unlawful actions against Dr. Garlington occurred outside the judge’s immunity protection, the plaintiff will proceed with civil action against the honorable Judge Patrick Clifford. Therefore, the Plaintiff is petitioning the court to reserve this date and freeze the clock pertaining to the 5 year limits to file a federal civil lawsuit against Judge Clifford.
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28. The defendant, Susan Clifford, made secret phone calls to Attorney Koch within the five-year timeframe. However, the evidence was not made available to the Plaintiff until November 13, 2015. Dr. Garlington asked Attorney David DeRosa to reveal these criminal acts committed by Susan Clifford. Attorney DeRosa stated he would not, and further said he would say that he could not recall if Attorney Koch had ever told him that Susan Clifford had called. After two years of pleading with Attorney DeRosa to expose Attorney Koch and Susan Clifford, the plaintiff decided to fire Attorney DeRosa and put forth his own motion pro-se to unveil the truth. It was not until the court hearing on November 13, 2015, when the Plaintiff addressed the issue directly to Judge Bright that Attorney DeRosa reluctantly admitted the truth about Susan’s secret phone calls to Attorney Koch. Up to that court hearing the Plaintiff had no way to move forward with this evidence because Public Defender David DeRosa said he would say that he could not recall this incident ever occurring. The Plaintiff had no idea whether DeRosa would lie or tell the truth in court. Therefore, this evidence was not officially available to bring forth in this Federal Civil Lawsuit until November 13, 2015.
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29. The plaintiff, Dr. Garlington, informed Attorney DeRosa two days before the hearing that if he lied in court he would have two people whom he had previously told about Susan’s secret calls to Attorney Koch come into court and testify that Attorney DeRosa had also told them that Susan Clifford pressured Attorney Koch to withdraw from the case and if he did not tell the truth he would perjure himself. Consequently, Attorney DeRosa decided to expose the defendant, Mrs. Susan Clifford, in court on November 13, 2015. The secret phone conversations between Theodore Koch III from Susan Clifford are State and Federal crimes which include but are not limited to Intimidation, Coercion, Collusion, Lies of Omission, Conspiracy, Obstruction of Justice, Withholding Evidence and Blackmail, etc.
VII. Claims for Relief
30. The actions of the defendant, Susan Clifford, phoning the Public Defender Theodore Koch and coercing him to withdraw from the plaintiff’s case to prevent herself from being arrested and imprisoned by the Federal Bureau of Investigations (FBI) for fraudulently forging the signatures of the Dolans on an $8.7M Coldwell Banker real estate document with the intent to deceive the Superior Court.
To Cover-up the Conflict of Interest in which she would have received over $240,000 commission from the sale of the Dolan’s multi-million beachfront home to NBA Boston Celtics star, Ray Allen, the victim’s stepson in the plaintiff’s, Dr. Garlington, Criminal Trial in which her husband, Patrick Clifford, was the Presiding Judge.
These criminal actions in collusion with Attorney Koch to conceal evidence of Conflict of Interest violated Connecticut’s Penal Codes 53a-139, forgery in the second degree and conspiring with others to obstruct the due course of justice with intent to deny the plaintiff equal protection of the law in violation of United States Codes 42 USC 1983, 1985 (2) and(3), along with the 5th, 6th and 14th Amendments to the United States Constitution.
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31. The actions of the defendant, Susan Clifford, employed her husband to blackmail the Plaintiff’s Attorney, Ted Koch, into withdrawing from the Garlington case. Susan’s husband, Judge Clifford, threatened to potentially destroy Attorney Koch’s career by making his clients suffer if he did not withdraw. Susan Clifford’s husband is the presiding judge in the New London Courthouse. He had the power to “Blackball” Attorney Koch with many of the judges in that court. New London is Theodore Koch’s primary location for employment because his law firm is in Lyme, CT, in close proximity and in the same county as the New London Courthouse. In a relatively small regional community if it were to become known that Attorney Koch’s clients were suffering because they were represented by him it could destroy his reputation and severely impede his career.
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32. The defendant, Susan Clifford’s, blackmail of the plaintiff’s attorney, Koch was not the first time she employed her husband, Judge Clifford, to make her criminal actions ‘disappear’. On June 30, 2004, the defendant was arrested for DUI (CFS No. 030000-12873, Incident CD2101). Since Susan had previously been arrested for the same offense, the Madison (CT) Police Department videotaped Mrs. Clifford’s actions during processing while in the holding cell (Video Tapes #1, 2, 3 & 4 logged into evidence). While in the cell, the defendant, Mrs. Clifford, became belligerent and ripped off some of her clothes in front of the camera and “exposed her upper torso several times.”
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33. The defendant, prior to blackmailing Ted Koch, employed her husband to erase her DUI charges. Consequently, Judge Clifford was able to have her DUI case transferred to different courts in an attempt to thwart prosecution. Mrs. Susan Clifford’s husband also formed a committee to expunge DUI charges for those who were arrested for DUI charges but did not have a subsequent arrest for the same offense during the pendency and disposition of the first arrest. This clearly demonstrates the defendant’s propensity to employ her husband, Judge Clifford, to abuse his power and absolve his wife from criminal actions she committed.
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34. The actions of defendant Coldwell Banker Real Estate Agency in enabling Susan Clifford to formulate and forge documents under the agency’s seal with the intent to deceive and misrepresent evidence in a court of justice indirectly colluded with Susan Clifford to obstruct the due course of justice, deny the plaintiff the equal protection of the laws and conspired in the forgery of documents in violation of the United States Codes 42 USC 1983, 1985 (2) and (3), the 5th, 6th and 14th Amendments to the United States Constitution and Connecticut’ Penal Codes 53a-48 and 53a-139s conspiring to commit forgery in the second degree.
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35. The actions of defendant Susan Clifford and Coldwell Banker Real Estate Agency, in colluding directly or indirectly to set in motion a conspiracy to obstruct the due course of justice with the intent to deny the plaintiff the equal protection of the law, violated the plaintiff’s civil rights, denied him the privileges and immunities enjoyed by citizens of the United States and caused him to be deprived of his liberty, in violation of 42 USC 1983 and 42 USC 1985 (2) and (3).
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36. The actions of defendant Susan Clifford and Coldwell Banker Real Estate Agency, in colluding directly or indirectly to set in motion a conspiracy to obstruct the due course of justice with the intent to deny the plaintiff the equal protection of the law, violated the plaintiff’s civil rights, denied him the privileges and immunities enjoyed by citizens of the United States and caused him to be deprived of the companionship of his wife and family for 9+ years. Spousal/family consortium is a constitutionally protected right under 42 U.S.C. § 1983.
VIII. Relief Requested
WHEREFORE, the plaintiff respectfully requests that this honorable Court grant the following relief:
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A. Issue a declaratory judgment stating that:
1. The actions of defendant, Susan Clifford, making calls to the plaintiff’s attorney, Theodore Koch, to coerce and collude with Attorney Koch which led him to withdraw from Dr. Garlington’s case on January 10, 2013.
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2. The defendant, Susan Clifford, employed her husband to blackmail the plaintiff’s attorney, Theodore Koch, which forced him to withdraw from the Garlington case.
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3. The actions of defendant, Susan Clifford, likely had other people call to intimidate and coerce the plaintiff’s attorney, Koch, which compelled him to withdraw from the case
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4. The actions of the defendants, Susan Clifford and Coldwell Banker Real Estate Agency, committed fraud by forging documentary evidence submitted to the Superior Court which deceived and concealed evidence of Conflict of Interest and improprieties which allowed Dr. Garlington’s Motion to Disqualify Judge Clifford to be denied, thereby preventing his wrongful conviction from being vacated and stealing his freedom as an American citizen. The defendant, Susan Clifford’s criminal actions violated Connecticut’s Penal Codes 53a-139, forgery in the second degree and conspiring with others to obstruct the due course of justice with intent to deny the plaintiff the equal protection of the laws in violation of United States Codes 42 USC 1983, 1985 (2) and (3), along with the 5th, 6th, and 14th Amendments to the United States Constitution.
B. Award compensatory damages in the amounts:
1. $20,000,000, jointly and severally against defendants Susan Clifford and Coldwell Banker Real Estate Agency for their violation and deprivation of the plaintiff’s civil rights, liberty, privileges and immunities in a conspiracy to obstruct the due course of justice;
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2. $20,000,000 jointly and severally against Coldwell Banker Real Estate Agency for enabling Susan Clifford to forge documents through her employment in the agency, for the purpose of deceiving the court and thereby acquiescing directly or indirectly in a conspiracy to obstruct the due course of justice.
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C. Award punitive damages in the amounts of:
1. $10,000,000 each against defendants, Susan Clifford and Coldwell Banker Real Estate Agency.
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D. Award punitive damages for loss of consortium. Past decisions have awarded $1 million for each
year wrongly imprisoned.
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E. Grant such other relief as it may appear that the plaintiff may be entitled to.
Facts related to Relief/Damages
I. Christian Warrior International
Dr. Ernest Garlington is the founder of Christian Warrior International (CWI), a Christian merchandise and licensing company. While building his company, Dr. Garlington achieved excellent trajectory of success. CWI’s extraordinary future profits estimated at over $100 million were destroyed because he was convicted of a crime he did not commit due to a “rigged” trial. CWI/Dr. Garlington is seeking $20,000,000 in damages from Susan Clifford and Coldwell Banker Real Estate Agency. The criminal actions of the defendants lead to Dr. Garlington’s wrongful conviction resulting in 9 years to date of false imprisonment.
II. New Opportunities, Inc.
Dr. Garlington would have become the CEO of New Opportunities, Inc. if he were not wrongly convicted. New Opportunities Inc. is a community action agency that serves Waterbury, Meriden, Torrington and 27 surrounding Connecticut towns, offering a variety of social service programs designed to eliminate poverty and assist people in need. Headquartered in Waterbury, CT and the city’s fourth largest employer, New Opportunities has additional offices in Meriden, Torrington, Danbury and Thomaston for the convenience of those they serve. Annually, more than 61,000 individuals benefit from programs offered at this agency, guided by the New Opportunities staff who help them find the way to meet their needs. Dr. Garlington worked at New Opportunities for 15 years, his entire professional career. He received his Master’s Degree and Ph.D. while employed at New Opportunities. The current CEO has a salary of $200K+ per year.
Dr. Garlington’s Formal Christian Education:
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Sacred Heart High School
Penn State University, M.Ed., Masters Counselor Education
Holy Cross College, BA in Psychology
South Florida Bible College & Seminary, Ph.D. Christian Counseling
NOTE: Some of the people on the following list of witnesses may be willing to testify to support the Relief/Damages claim.
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1. Christian Warrior International – CWI Board Members, Investors and Primary Witness List
2. NY – Manhattan Investment Law Firm
3. Walt Disney Executive – Quote “CWI is a $Billion-dollar company.”
4. NBA former Player, Heisman Trophy winner
5. Wall St. Banker Quote “I’m convinced CWI will become a $Billion-dollar company.”
6. Rhode Island Jewelry Company – produces Tiffany’s jewelry, produced NFL Super Bowl ring,
Quote, “we will devote our entire company to producing and distributing the CWI jewelry line.”
7. 3 NFL Coaches
8. Mars Bars (Snickers) and NBA former executive,
Quote “Christian Warrior can become the largest Christian merchandise company in the world.”
9. Catholic Church – Connecticut Archdiocese
10. Yale Divinity
11. CWI Business Plan Developer
12. New Opportunities, Inc. – Primary Witness List
1. New Opportunities – CEO
2. New Opportunities Management Team Director
Certification and Closing
Under Federal Rule of Civil Procedure 11, by signing below, I certify to the best of my knowledge , information and belief that this complaint: (1) is not being presented for an improper purpose, such as to harass, cause unnecessary delay, or needlessly increase the cost of litigation; (2) is supported by existing law or by a non-frivolous argument for extending, modifying or reversing existing law; (3) the factual contentions have evidentiary support or, if specifically so identified will likely have evidentiary support after a reasonable opportunity for further investigation or discovery; and (4) the complaint otherwise complies with the requirements of Rule 11.
I agree to provide the Clerk’s Office with any changes to my address where case related papers may be served. I understand that my failure to keep a current address on file with the Clerk’s Office may result in the dismissal of my case.
Date of signing: May 2, 2017
Respectfully submitted
_____________________________
Dr. Ernest Garlington
No. 334928
MacDougal Correctional Facility
1153 East Street South
Suffield, CT 06080